In Brief
The appellant challenged his murder conviction under IPC Section 302, arguing that a Test Identification Parade (TIP) was invalid because his photograph had appeared in a newspaper before the TIP was conducted. The Supreme Court dismissed the appeal, holding that substantive evidence of identity comes from court identification, not the TIP. The TIP is merely an investigative aid governed by CrPC Section 162. Since the injured eyewitness credibly identified the appellant in court, conviction could be sustained. The appellant's counsel failed to establish through proper cross-examination that an unmuffled photograph was published; the witness's own testimony contradicted this. The High Court's reasoning was approved.
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